Legal

Privacy policy

Draft, pending legal review, not yet in effect

This text is a working draft. Bracketed items are still to be filled in. It does not bind anyone until a final version is published here with an effective date.

Effective date: [Effective date]

Who we are

Zaproo Search is a hosted site search and AI shopping assistant for online shops. It is run by [Company legal name], [Registered address], company number [Registration number] ("Zaproo", "we"). Our data protection contact is [DPO contact].

This policy covers two groups of people:

Customers and their team members who sign up and use the dashboard. For their account data we are the controller.
Shoppers who search or chat on a customer's shop. For their data the shop is the controller and we process it on the shop's behalf, under our data processing agreement. The shop's own privacy policy applies to them.

Data we collect from customers

Account data: email address, password (stored only as a hash), company name, organization and team membership, roles.
Sign-in and security data: sessions with the IP address and browser they came from, password reset and email verification tokens, and an audit log of changes made in the dashboard with the IP address they came from, including changes our staff make while signed in as you.
Billing data: plan, usage and invoices.
Service data you send us: product catalogs and other documents you index, feed URLs, search settings, and the instructions and settings of AI assistants.

We use this data to provide the service, secure accounts, send service emails (verification, password reset, usage alerts, the weekly digest you can switch off), bill and support you, and meet legal obligations. The legal bases are the contract with you (GDPR Art. 6(1)(b)), our legitimate interest in running and securing the service (Art. 6(1)(f)) and legal obligations (Art. 6(1)(c)).

Data we process for shops

Search and analytics: search queries, clicks and other events the shop sends, with a salted hash of the shopper's session id, the device type and country. Kept per the project's analytics retention setting.
AI assistant conversations: the shopper's messages, the assistant's answers, the products shown, a random visitor id stored in the shopper's browser, and the site the chat ran on. Deleted after the assistant's retention period (7 to 365 days, 90 by default).
IP addresses: used for rate limiting in short-lived counters. They are not stored with conversations or search logs.

To write answers, the assistant sends shopper messages, recent conversation history, the shop's instructions and fields from the shop's catalog to an AI model provider. Which providers we use and how they handle the data is explained in How the AI assistant handles data with model providers. Zero data retention with these providers is [to confirm per provider].

Who we share data with

We use sub-processors for hosting, storage, email delivery and AI models. They are listed on the sub-processor list. We do not sell personal data and do not use customer or shopper data to train AI models.

International transfers

Our hosting is in [EU region, to confirm]. Some AI model providers process data outside the EEA. Where they do, the transfer relies on [Standard Contractual Clauses / the EU-US Data Privacy Framework, to confirm per provider].

Retention

Account data is kept while the account exists and deleted within [N] days after it is closed, except what we must keep for accounting. Conversations and search logs follow the retention settings above. Database backups are kept for 30 days and search index snapshots for 14 days, so deleted data can remain in a backup for that long.

Your rights

Under the GDPR you can ask for access to, correction, deletion or a copy of your data, object to or restrict processing, and withdraw consent where processing relies on it. Write to [Privacy contact email]. Shoppers should contact the shop first; we help the shop answer. You can also complain to a supervisory authority, for example the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), the Latvian Data State Inspectorate or the Lithuanian State Data Protection Inspectorate, or the authority where you live. Our lead authority is [Lead supervisory authority].

Cookies

The dashboard stores what it needs to keep you signed in. The search and assistant widgets store a random id in the shopper's browser to keep a session and a conversation together. [Cookie and storage list, to confirm.]

Security

AI provider keys are encrypted at rest. Each customer's data is kept apart from every other customer's, and changes our staff make in a customer's account are recorded in the audit log. [Further measures, such as encryption in transit and at rest, to confirm against the hosting setup.]

Changes

We will post changes here and tell customers by email before a material change takes effect.